When can a contractor transfer original paper documents to an electronic recordkeeping system?

OFCCP regulations and policy allow for the transfer of original paper records to an electronic recordkeeping system provided (1) the medium used accurately reproduces the paper original records, (2) the electronic records constitute a duplicate or substitute copy of the original paper records under Federal law, and (3) the electronic records can be converted back into legible and readable paper copies and provided to OFCCP upon request.

If a contractor transfers its personnel paper records to an electronic recordkeeping system, what records must be furnish to OFCCP when requested?

OFCCP regulations require contractors to permit OFCCP access to its records
during an OFCCP compliance evaluation or complaint investigation. These requirements
apply to both paper and electronic records. See 41 CFR 60-1.43, 60-300.81,
and 60-741.81. Thus, all of the contractor's electronic records must be made
readily available for review, and must be readable and capable of being copied
by OFCCP.

When can a contractor dispose of a paper original record that has been converted to an electronic record?

In general, the original paper record may be disposed of any time after it has been transferred to an electronic recordkeeping system. However, the original paper record may not be disposed of if the electronic copy would not accurately reproduce the original record.

Do the record retention requirements that apply to paper records also apply to records maintained electronically?

Yes. If records are maintained electronically, contractors must take care to ensure that the electronic records comply with the record retention and access regulations. The OFCCP regulations at 41 CFR 60-1.12, 60-300.80, and 60-741.80 require that contractors preserve complete and accurate personnel records. The regulations at 41 CFR 60-1.43, 60-300.81 and 60-741.81 also require that contractors permit OFCCP access to their records, including computerized records, for inspection and copying.